Hojo

Not to go off topic too much, but why the anxiety? Set the plans up assuming non-coverage. Make deposits. If they are covered, then great, you can deposit an additional $35k or so and deduct. Amend your return and they're done.

This can easily happen if the plan is overfunded either by high investment earnings or funding the max in prior years. I'd trust the actuary is telling you the correct results.

Another year and more silence on this issue. From what I can see, if you enter it on 8j and enter nothing in 13c it is now a warning and not an error so you can still submit the filing. 8j and 13a add up so I would assume anyone looking at the form would understand what happened.

I think the only possibility is to purchase some type of variable annuity with a cap of the 415 limit. I'd agree with Effen and Bird in that this is a terrible idea and you should use your consulting skills to have them consider amending the plan to allow lump sums instead of including this......stuff.

This is what I was thinking and I thought we had received some guidance on this, but haven't been able to put my hands on anything.

I remember seeing something about future interest crediting rate assumptions for Actual ROR plans to help pass non-discrimination and minimum participation tests. Does anyone have any reference for this. I'm looking at something where the actual ROR was less than 1% so I am having difficulty with my rank and file passing minimum participation using that as my projected rate.

This is the key, "Assume minimum required contribution requirement is not an issue, whether this $1,000 is deposited or not." If they make the minimum required contribution then who cares?

What does the plan document say? Overall, yes you can have in-service distributions, but whether your particular plan allows them is defined by the document.

I'm guessing the reasoning is that there is an AFTAP on the SB which is signed and dated. Some could take that to mean the AFTAP was certified as of the date of the signed SB.

I think the problem here as an answer to your question is that if a plan sponsor wanted to do that almost all of us would say, you can't. Or at least we would say you shouldn't try.

Your actuary is likely following the rules stated in the plan document to the letter. This is my personal opinion and I could be wrong, but I would follow the actuary's advice and take the benefit now since it will continue to decrease. You can ask the plan sponsor (your employer) for a copy of the plan document but know that this is literally their specialty. Again, they could be wrong and actuaries have and do make mistakes on this stuff, but I doubt that they are in this case.

2 options are available: 1) The PBGC missing participants program now covers nonresponsive participants so you could transfer the funds that way. This is the easiest option. 2) There are companies that will bid on one or two benefits, not many, but they exist. Go to one of the de-risking firms out there and they can help you. If you need help finding one, let me know.

"Definitely determinable"

I'm seeing that there is relief for the 5500 filing due date for those impacted by Hurricane Ida but I wanted to verify that this does not currently extend the date required contributions are due past September 15th. I don't believe it has, but wanted to double check.

Well it appears we have an answer. No 5500 for 2020 required for plans adopted after December 31, 2020. https://content.govdelivery.com/accounts/USIRS/bulletins/2eba346

If the plan is not paid out until 2020 then they still have a plan in 2020 even if the plan termination date in the document is 12/31/2019.

Related question - What do you do about a new plan for 2020 and a 5558? Does this effectively put the latest adoption date as 7/31 since you'd have to file a 5558 by then to extend the deadline?

Yeah, the plan sponsor has been super flaky about getting me data as well. That's a different issue. If I at least had a copy of the actuarial valuation report for a single year I could probably move forward pretty easily. I'm able to pull the prior SB and such from EFAST so that's not difficult to obtain. But the provisions attached to the SB aren't the cleanest and I'd love a copy of the document. I've reached out to the ABCD already so we'll see what they say as well.

So I'm wondering if anyone has any suggestions about how to handle the following situation: We were recently engaged by a client to takeover their actuarial work. As standard practice, the client messaged the prior actuary asking them to share historical plan information and discuss the plan with us. We followed up with a formal request for data and heard nothing. After repeated requests with no response we started calling the prior actuary with no response and no ability to leave a voicemail. Well today I got through on the phone (Yay!). I introduced myself and the prior actuary immediately hung up. I called back a few hours later and was told, "**** you!" and he immediately hung up. Any thoughts?

I'm assuming that was thinly veiled sarcasm by Bob. Heck, I just got yelled at by an advisor because I told the client that their 32% investment return for 2020 was too high and can have significant consequences in the future. The communication was probably there and ignored.

There was amendment to create the short plan year indicating that there would be no CB accrual. It's more of a matter of whether the Gateway is for combine plans or the singular PS plan (7.5% vs 5%).

The client wanted to move to a calendar year and thus created a short plan year 10/1/2020 - 12/31/2020. The CB document indicates 1,000 hours required for an accrual so it appears there is no CB accrual during the short plan year. In this case, I'm assuming we still use the combined plan gateway rules, but there is no CB accrual when generating the required gateway percentage. I feel like I'm overthinking this so just looking for clarity.

I feel that you're reading more into in than is there. "A plan sponsor may elect not to have the amendments made by this section apply to any plan year beginning before January 1, 2022." Is a plan year beginning January 1, 2021 a plan year beginning before January 1, 2022? Yes? If so, then the plan sponsor may elect not the have the amendments made by this section apply.

Without any actual detail of the plan, this seems about right. Since your dad never made an election prior to his death then he would fall under the QPSA rules. Essentially he was a vested terminated participant who was assumed to have made an election the day before his death of a joint and 50% annuity. Then he dies and his surviving spouse is eligible for that 50% benefit as a single lifetime annuity.

I think you do it as you would any other 110% calculation. Calculate the FT and take the participant out. Calculate the Assets and take the LS out. Is the Assets/FT > 110%?